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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Metals and Controls

Corp. Subsurface

Exposure Model 

White Paper 

National Institute for Occupational 

Safety and Health

April 23, 2018

Pat McCloskey

Mutty Sharfi

Oak Ridge Associated Universities Team

Reviewed By: 

Peter A. Darnell, CHP, RRPT

Dr. James W. Neton, Ph.D. CHP

Division of Compensation Analysis and Support
White Paper Metals and Controls Corp. Subsurface Exposure Model April 23, 2018

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

INTRODUCTION

NIOSH presented the Evaluation Report (ER) for SEC-00236, Metals and Controls Corp. 

(M&C) to the Advisory Board on Radiation and Worker Health (Board) on August 24, 2017. At 

the conclusion of that presentation, a petitioner raised a concern about the adequacy of the ER in

addressing subsurface work.

On September 5, 2017, in response to this concern, NIOSH initiated plans to continue research 

and further develop SEC-00236, including a review of monitoring records in the Site Research 

Database (SRDB) and a search for former workers to interview.

From October 24 through October 26, 2017, the National Institute for Occupational Safety and 

Health (NIOSH), Oak Ridge Associated Universities (ORAU), and Sanford Cohen & Associates 

(SC&A) personnel interviewed 12 former M&C workers and individuals knowledgeable of 

subsurface work. By March 13, 2018, information obtained from the interviews was upload into 

the SRDB (ORAUT, 2017-a,-b, -c, -d, -e, -f, -g, -h, -i, -j, -k, -l). Interviewers asked questions 

regarding the frequency and duration of subsurface work, including utility and drain line 

maintenance, and new equipment installations. During the interviews it became apparent that 

Building 10 experienced recurring issues with water drainage (ORAUT, 2017-b, PDF p. 6; 2017-

e, PDF p. 5; 2017-g, PDF p. 8; 2017-i, PDF p.7; 2017-j, PDF, p. 5), and underwent multiple 

equipment change-outs that necessitated subsurface work. Although this work was sporadic and 

sometimes emergent in nature, it exposed workers in a manner that did not agree with the 

method described in the ER (surface contamination resuspension). Interview responses also 

showed that covered workers performed significant subsurface work in areas outside of Building 

10 (ORAUT, 2017-h, p. 11; 2017-j, PDF pp. 4, 9), and because the site was non-union, the work 

could be assigned to several different groups (ORAUT, 2017-b, PDF p. 6; 2017-c, PDF p. 12;

2017-g, PDF pp. 4, 8, 11), which is also corroborated by Nuclear Regulatory Commission 

(NRC) inspections (NRC, 1981-1982, PDF p. 13).

On November 8, 2017, the Board, SC&A, DCAS, and ORAU team members held a 

teleconference to discuss technical issues associated with developing exposure models regarding 

subsurface and other work. On February 6, 2018, NIOSH obtained additional monitoring data 

regarding remediation work performed by Creative Pollutions Solutions in 1992 and 1994 (CPS, 

1992-b; CPS, 1994), and on February 13, 2018, NIOSH received SC&A’s report titled, Review 

of SEC Petition ER SEC-00236.

This White Paper provides a revised exposure assessment model based on data obtained since the 

SEC-00236 ER was written. 

INSIDE BUILDING 10

The subsurface environment inside the walls of Building 10 that workers were exposed to is well 

characterized. The residues inside the worst case (i.e., Priority-1) drain lines are characterized in 

Exhibit 1 (Weston, 1996-a) provided by the petitioner. The [Name Redacted], who started 

working in the Environmental Safety and Health department in 1983 and was the [Job Title 
White Paper Metals and Controls Corp. Subsurface Exposure Model April 23, 2018

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Redacted], stated that Exhibit 1 represents conditions prior to Decontamination and 

Decommissioning (D&D) activities; therefore, it offers “good insight into conditions to which 

employees were exposed” (Affidavit, 2016, PDF, p. 4). In Exhibit 1, characterization methods 

are described, and sample locations and analytical results are provided (in pCi/g) for pipe 

residues. Radiation surveys were also performed with Nal(Tl) gamma scintillation detectors

(Weston, 1996-a, PDF p. 14). The locations selected for sampling were based upon: 

• Review of "as-built" diagrams; 

• Historical information and/or suspected transfer of contaminated material in drain lines; and 

• Radiological survey data from previous investigations and removal actions (p. 7). 

The facility map depicts the relative locations of the drain lines (Weston, 1996-c, PDF pp. 172, 

173) and classified according to their sediment content and total uranium concentrations in pCi/g 

as follows: 

• Priority-1 1,000 to 53,000 (max); 

• Priority-2 500 to 1,000; and 

• Priority-3 Less than 500. 

An October 1996 report from remediation contractor Weston describes the work controls and 

exposures associated with the removal of the worst-case drain lines. The report includes 

volumetric (pCi/g) soil-sample data, breathing-zone air-monitoring data (Highest monthly 

average reported as <2.4E-12μCi/ml), and assigned doses for the work (20 mrem/quarter CEDE) 

(Weston, 1996-c, PDF p. 22).

The Priority-1 drain lines, worked on by M&C employees and removed by Weston, contained 

the highest subsurface radioactive material concentrations to which workers were exposed. 

According to the D&D project manager, “...in the exterior soils, [contamination] was not 

insignificant. Although, I will tell you that clearly the “mother lode,” to use a colloquial term, 

was in drains in Building 10” (ORAUT, 2017-c, PDF p. 10). 

AREAS OUTSIDE OF BUILDING 10

Some workers performed maintenance and new installations that required them to dig in soils in 

outside areas contaminated with radioactive material from Atomic Weapons Employer (AWE) 

operations (ORAUT, 2017-j, PDF pp. 4, 9; ORAUT, 2017-h, PDF p. 11). These subsurface areas 

are well characterized. 

At the request of the NRC, ORAU conducted a radiological survey of the waste burial site 

located to the southwest of Building 12, and the outdoor area surrounding Building 10 during 

April and May of 1984 (Sowell, 1985, PDF p. 9).The survey included a ground-penetrating radar 

survey to locate buried materials. Areas were gridded and surveyed with Nal (Tl) gamma 

scintillation detectors to identify locations for volumetric sampling (Sowell, 1985, PDF p. 10). 

Surface samples were collected and boreholes were drilled 2 to 3.5 meters deep to collect 

additional samples (Sowell, 1985 PDF pp. 11, 13). Soil samples analyzed by gamma 
White Paper Metals and Controls Corp. Subsurface Exposure Model April 23, 2018

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

spectrometry included radionuclides of U-238, U-235, Th-232, and Ra-226 (Sowell, 1985, PDF 

p. 13). Analytical results are found in Tables 4 and 5 of the survey (Sowell, 1985, PDF pp. 62-

76) for surface samples from the Burial Area, and in Table 6 (Sowell, 1985, PDF pp. 77-82) for 

the borehole samples. Table 11 contains the analytical results for the surface samples taken of the 

outdoor area surrounding Building 10 (Sowell, 1985, PDF pp. 92-95). In their summary, ORAU 

concluded that the results indicated the presence of isolated areas of surface and subsurface 

contamination that were located mainly within the boundaries of the suspected burial site; 

however, there were small areas of surface contamination outside the burial site and in a few 

locations around Building 10 (Sowell, 1985, PDF p. 23).

Creative Pollutions Solutions (CPS) summarized the results from the 1984 ORAU subsurface 

characterization of the Burial Area in a 1992 report which included updated sampling and 

analysis that supported the 1984 ORAU results and conclusions (CPS, 1992-a, PDF p. 5). The 

1992 CPS report also documents a pilot study where CPS excavated contaminated portions of the 

Burial Area while performing air monitoring. Four out of five breathing zone results were less 

than Minimum Detectable Activity (MDA), and the fifth resulted in 4.1E-2 MPC-h (CPS, 1992-

a, PDF p. 25).

The Metals Recovery Area near Building 5 was the location where some open burning occurred 

during AWE operations. Subsurface volumetric soil sample data are available (CPS, undated, 

PDF pp. 7-20; Texas Instruments, 1994, PDF p. 9).

The soils in the Stockade Area, located between Buildings 10 and 11, were contaminated 

because of staging wastewater and pickling acid solutions in drums on the ground within an area 

enclosed with a stockade fence (Weston, 1996-b, PDF p. 110; Texas Instruments, 1994, PDF p. 

33).

The Railroad Spur Area is located between the Metals Recovery and Stockade areas. M&C did 

not handle radioactive material in this area; however, it is believed that soils became 

contaminated due to transference from the two neighboring areas (Weston, 1996-b, PDF p. 110-

113; Texas Instruments, 1994, PDF p. 33).

The Building 12 West and South Lawn Areas were contaminated during the 1968 Building 12 

construction project when contaminated soils from the Burial Area were transferred during final 

grading (Weston, 1996-b, PDF pp. 108-110; Texas Instruments, 1994, PDF p. 35).

BOUNDING EXPOSURE MODEL

ORAUT-OTIB-0070 (2012) provides guidance on mass-based assignments used here to 

calculate air concentrations, given volumetric sample data and appropriate dust loading factors. 

In addition, former workers provided information regarding frequency, duration, and safety 

controls associated with the subsurface work that allows NIOSH to determine occupancy rates. 

Based on information gained from interviews, workers could have had as much as 1 month per 

year exposure to subsurface work (ORAUT, 2017-i, PDF p.7; ORAUT, 2017-j, PDF p. 5; 
White Paper Metals and Controls Corp. Subsurface Exposure Model April 23, 2018

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

ORAUT, 2017-e, PDF p. 5; ORAUT, 2017-b, PDF p. 6; ORAUT, 2017-g, PDF p. 8). M&C 

workers in the Facilities Construction and Maintenance Services Organization (Facilities) or 

Production Machine Operators/Helpers and Production Repair & Maintenance (R&M) 

organizations having access to, and worked within production areas had the potential for 

subsurface exposure (ORAUT, 2017-c, PDF p. 11).

Inside Building 10 Volumetric Sample Data

The subsurface work environment inside Building 10 was characterized with 44 soil samples

collected prior to remediation of the Building 10 drainage system. Those 44 samples were

analyzed for uranium with isotopic identification and were compiled in a spreadsheet where the 

geometric mean (147.12 pCi/g) and geometric standard deviation (7.68) were calculated.

Outside Areas Volumetric Sample Data

The following outside areas including the area surrounding Building 10, in the former Burial 

Area, the Metals Recovery Area, the Building 11 Stockade Area, the Building 11 Railroad Spur 

Area, and in the Building 12 West and South Lawn Areas were characterized with 292 soil 

samples collected prior to remediation. Two hundred twenty-nine (229) of these samples were 

analyzed for gross alpha, and the remaining 63 were analyzed for uranium and thorium using 

isotopic identification.

The gross alpha and uranium samples were compiled in a spreadsheet where the geometric mean 

(53.52 pCi/g) and geometric standard deviation (4.54) were calculated. Since the calculated 

geometric standard deviation is less than the default value listed in Battelle-TBD-6000, Section 

5.2.1, the default value of 5 will be used.

The gross alpha and thorium samples were compiled in a spreadsheet where the geometric mean 

(25.94 pCi/g) and geometric standard deviation (5.36) were calculated.

Dust Loading

Worker affidavits and interviews described the subsurface work as very intrusive and included

accessing contaminated materials that had accumulated for decades without work controls to 

mitigate the hazard. The default dust-loading value of 100 μg/m3 value suggested in ORAUTOTIB-0070 (2012) and NUREG/CR-5512 (1992), meant for use in screening analysis as a longterm average, is not appropriate for M&C subsurface work where workers actively disturbed the 

contaminated material during episodic responses throughout a given year. ORAUT-OTIB-0070 

(2012) provides justification for increasing resuspension factors, as operations become more 

vigorous (PDF p. 8).

In addition, this justification is corroborated by research performed to determine dust-loading

factors during contaminated-soil excavation activities for the Mound Plant Canal Clean-up 

Project (Taulbee, 2018). During the Mound Project, air-sample collection media were weighed 

before and after taking each sample to determine their dust loading in grams. The volume flow 
White Paper Metals and Controls Corp. Subsurface Exposure Model April 23, 2018

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

rate was recorded before and after taking each sample, then the average flow rate was determined 

and multiplied with the sampling duration to determine the total volume of air in cubic meters.

In total, data from 294 hi-volume air samples were recorded to get a distribution of the dustloading factor (Figure 1). From the Figure 1 plot, the geometric mean is identified as 7.18 x 10-5

g/m3 and the 95th percentile as 2.2 x 10-4 g/m3. 

Figure 1. Measured Dust-loading Factor from High Volume Air Sample Data taken spring 1997 during 

Mound Canal Project.

NIOSH analyzed operations at Mound and M&C to determine if the Mound dust-loading data 

could be used as a surrogate for dust loading at M&C in accordance with OCAS-IG-004. The 

following underlined headings show the criteria listed in Section 3 of OCAS-IG-004 and 

describes how the criteria are applicable to dust loading at M&C. 

Source Term: NIOSH has knowledge of the types and general quantities of material processed 

at M&C. NIOSH has access to extensive sample data and process information of uranium and 

thorium-generating activities at M&C as referenced above. 

Facility and Process Similarities: Excavation activities for the Mound Plant Canal Clean-up 

Project occurred over several months during the spring of 1997. The Mount Plant is located near 

Miamisburg in western Ohio. Excavation activities at Mound involved using a backhoe to 

remove soils. Using water as a dust suppressant was sporadic and not consistently applied. In 

addition, windbreaks, tents, or ventilation were not used. 
White Paper Metals and Controls Corp. Subsurface Exposure Model April 23, 2018

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Both outside and inside subsurface work at M&C occurred from 1968 through 1996. As with 

Mound’s excavation activities, outside subsurface work involved using a backhoe to remove

soils. Inside subsurface work at M&C involved shoveling and snaking soils and drain residues. 

Also like Mound, there was sporadic and inconsistent application of water used as a dust 

suppressant during outside and inside subsurface work. Windbreaks, tents, or ventilation were 

also not used.

Therefore, the Mound excavation activities and the outside subsurface work at M&C are 

substantially similar. There could be differences that make the Mound excavation activities more 

likely to generate airborne dust than the inside subsurface work at M&C; however, the Mound 

data provide a plausible upper bound for M&C dust loading.

Temporal Considerations: The era of excavations at Mound (1996) and at M&C (1968-1996) 

are similar enough when considering the equipment, methods, and work performed at both sites. 

For example, the hi-volume air samplers used for the Mound study are still an appropriate 

method for quantifying dust loading to this day. Furthermore, the passage of time has not 

significantly altered backhoe operations, or their ability to generate airborne dust.

Data Evaluation: The quality of the mound surrogate data, depicted in Figure 1 above, can be 

described as having a high degree of precision and consistency throughout the 294 samples, with 

a geometric standard deviation of 2.167.

Review of Bounding Exposure Models: The geometric mean (7.18 × 10-5 g/m3) and 95th

percentile dust-loading factor (2.2 × 10-4 g/m3) calculated from the Mound study are realistic to

use for M&C subsurface exposure modeling. The dust-loading factor is more than double the 

ORAUT-OTIB-0070 (2012) default value (described above to be unrealistically low for

modeling M&C operations).

In addition to the OCAS-IG-004 criteria, another method to assess if the 95th percentile dustloading factor is appropriate for modeling M&C subsurface work is to compare the urinalysis 

results for remediation workers to the postulated model. CPS conducted remediation of the 

Burial Area in 1993 (CPS, 1993), which involved the use of a backhoe, hand shoveling, and 

screen separation of soils. CPS’s use of water as a dust suppressant was sporadic and not 

consistently applied largely because the water table was encountered at a depth of approximately 

6 feet. In addition, CPS did not use windbreaks, tents, or ventilation. During this work, in vitro

bioassay was performed for all site personnel requiring access to the Burial Area Exclusion Zone 

during excavation. The bioassay process involved fluorometric analysis of uranium within urine. 

At no time did the bioassay results exceed action levels (45 pCi/L) specified within the Health 

and Safety Plan (CPS, 1992-b, PDF p. 30), and all reported values were less than 4 μg/L total 

uranium (CPS, 1992-b, PDF p. 49).

In 1994, CPS conducted remediation of the Metals Recovery Area using the same methods as 

before; however, they performed bioassay for only the primary excavation personnel. The scope 

of uranalysis was limited this time based on air sampling results. The bioassay process again 
White Paper Metals and Controls Corp. Subsurface Exposure Model April 23, 2018

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with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

involved fluorometric analysis of uranium within urine, and all reported bioassay results were 

less than 1 μg/L total uranium (CPS, 1994, PDF p. 31). 

NIOSH projected the amount of uranium that could be collected from a reference man breathing 

air at a concentration of the proposed 95th percentile dust-loading factor (2.2 × 10-4 g/m3) for 30 

days. The calculation determined that M&C subsurface workers, for the three uranium solubility 

classes, should have an expected excretion rate of Type F 268 μg/L, Type M 40 μg/L, and Type 

S 1.2 μg/L at the end of a 30 day exposure. Comparing these calculated results with the measured 

results for the CPS workers demonstrates that the selected dust-loading factor is bounding and 

claimant favorable. 

For comparison and perspective, it may be useful to consider the full-scale remediation of 

M&C’s worst-case subsurface contamination. A report from remediation contractor Weston, 

from July 1995 through September 1996, describes the work controls and exposures associated 

with extensive remediation of the Building 10 subsurface. During this work, Weston removed 

and disposed of all the Priority-1 drain lines and surrounding soils, including 520 linear feet (lf) 

of 4-inch vitreous clay drainpipe, 400 lf of 4-inch cast iron drainpipe, and 360 lf of 4-inch 

polyvinyl chloride drainpipe. An additional 620 lf of Priority 2 drainpipes were decontaminated 

in place during this work. Standard removal techniques included the application of concrete 

saws, breakers, and heavy equipment such as Bobcats and backhoes. No respiratory protection 

was required, and safety measures such as dust suppressants, containment tents, or ventilation 

were used sparingly. Comprehensive personal monitoring was performed, and all Weston 

workers performing this remediation of the “motherlode of M&C contamination” were assigned 

doses of 20 mrem/quarter TEDE (Weston, 1996-c, PDF p. 21). 

Therefore, the default ORAUT-OTIB-0070 (2012) dust-loading value will be increased to the 

95th percentile value of 2.2 x 10-4 g/m3

 (220 μg/m3) from the Mound Project study, and when 

multiplied with the geometric mean of the applicable volumetric sample data, results in air 

concentrations of: 

• Inside uranium 3.24 E-14 μCi/ml; 

• Outside uranium 1.18 E-14 μCi/ml; and 

• Outside thorium 5.71 E-15 μCi/ml. 

Based on affidavits and interview responses, NIOSH will assume an occupancy rate of 1 month 

per year (i.e., 173 hours or 22 workdays). If the subsurface work area (e.g. inside or outside) 

cannot be determined, the most claimant favorable work location will be assigned. Subsurface 

workers will also receive assigned residual exposures for the remaining 11 months of each year 

at the same rate as the other workers that did not perform subsurface work. 

Ingestion Rates

Ingestion rates were determined using NUREG/CR-5512 (1992) Volume 1, Section 6.3.2 

methods (50 mg/workday). 
White Paper Metals and Controls Corp. Subsurface Exposure Model April 23, 2018

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

External Exposures

Film badges at the end of AWE operations (i.e., 1967) were processed quarterly by Landauer. 

NIOSH will use all of the 1967 results and determine the quarterly, geometric mean dose, and 

the geometric standard deviation. Since the subsurface work lasted no more than one month per 

year, external exposures will be assigned at the rate of one third the quarterly dose rate

determined for the beginning of the residual period using the quarterly geometric mean dose and 

geometric standard deviation. No source-term depletion will be applied because of the potential 

for the subsurface environment (e.g., inside clogged drains) to be less impacted by environmental 

reduction factors.

CONCLUSION

NIOSH has considered all of the information presented in this paper and has used it to develop a

subsurface exposure model for Metals and Controls Corp. that accounts for the descriptions of 

work by former employees, pre-remediation sample data, and a realistic dust-loading model.

NIOSH believes that this model adequately bounds subsurface exposures experienced by M&C 

workers during the residual radiation period.
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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

REFERENCES

Affidavit, 2016, Affidavit in Support of SEC-00236 Petition Basis; Name Redacted; August 13, 

2016; SRDB Ref ID: 170329 

CPS, undated, Appendix D, Radiological Survey Results, Appendices 1-4; assuming author is

Creative Pollution Solutions, Inc. (CPS) based on prior work and reports; undated; SRDB Ref 

ID: 165968 

CPS, 1992-a, Radiological Characterization of Texas Instruments, Incorporated-Attleboro 

Industrial Facility; Creative Pollution Solutions, Inc. (CPS); 1992; SRDB Ref ID: 164755 

CPS, 1992-b, Radiological Health and Safety Plan—Appendix A, Health and Safety Activities 

During Remediation of the Texas Instruments Incorporated Attleboro Site; Creative Pollution 

Solutions, Inc. (CPS); modified September 1, 1992; SRDB Ref ID: 169474 

CPS, 1993, Remediation of the Former Radioactive Waste Burial Site (NRC License SNM-23); 

Creative Pollution Solutions, Inc. (CPS); September 1993; SRDB Ref ID: 24626 

CPS, 1994, Radiological Health and Safety Plan—Appendix A, Health and Safety Activities

During Remediation of the Texas Instruments Incorporated Attleboro Site; Creative Pollution

Solutions, Inc. (CPS); April 24, 1994; SRDB Ref ID: 169475 

NRC, 1981-1982, NRC Inspection Reports; U.S. Nuclear Regulatory Commission (NRC); 

various dates from 1981-1982; SRDB Ref ID: 161187

NUREG/CR-5512, 1992, Residual Radioactive Contamination From Decommissioning: 

Technical Basis for Translating Contamination Levels to Annual Total Effective Dose 

Equivalent, Final Report, Volume 1; NUREG/CR-5512, PNL-7994; U.S. Nuclear Regulatory 

Commission; October 1992; SRDB Ref ID: 23558 

OCAS-IG-004, The Use of Data from Other Facilities in the Completion of Dose

Reconstructions Under the Energy Employees Occupational Illness Compensation Program Act, 

Rev. 0; Office of Compensation Analysis and Support (OCAS); effective August 21, 2008; 

SRDB Ref ID: 49029

ORAUT (Oak Ridge Associated Universities Team), 2017-a, Interview Worker #1; documented 

communication with former Metals and Controls Corporation worker; October 24, 2017; SRDB 

Ref ID: 169918

ORAUT (Oak Ridge Associated Universities Team), 2017-b, Interview Worker #2; documented 

communication with former Metals and Controls Corporation worker; October 24, 2017; SRDB 

Ref ID: 170018 
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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

ORAUT (Oak Ridge Associated Universities Team), 2017-c, Interview Worker #3; documented 

communication with former Metals and Controls Corporation worker; October 24, 2017; SRDB 

Ref ID: 169920

ORAUT (Oak Ridge Associated Universities Team), 2017-d, Interview Workers #3 and #4; 

documented communication with former Metals and Controls Corporation worker; October 24, 

2017; SRDB Ref ID: 169925

ORAUT (Oak Ridge Associated Universities Team), 2017-e, Interview Worker #5; documented 

communication with former Metals and Controls Corporation worker; October 24, 2017; SRDB 

Ref ID: 169916

ORAUT (Oak Ridge Associated Universities Team), 2017-f, Interview Worker #6; documented 

communication with former Metals and Controls Corporation worker; October 25, 2017; SRDB 

Ref ID: 169921

ORAUT (Oak Ridge Associated Universities Team), 2017-g, Interview Worker #7; documented 

communication with former Metals and Controls Corporation worker; October 25, 2017; SRDB 

Ref ID: 169938

ORAUT (Oak Ridge Associated Universities Team), 2017-h, Interview Worker #8; documented 

communication with former Metals and Controls Corporation worker; October 25, 2017; SRDB 

Ref ID: 169923

ORAUT (Oak Ridge Associated Universities Team), 2017-i, Interview Worker #9; documented 

communication with former Metals and Controls Corporation worker; October 25, 2017; SRDB 

Ref ID: 169924

ORAUT (Oak Ridge Associated Universities Team), 2017-j, Interview Worker #10; documented 

communication with former Metals and Controls Corporation worker; October 26, 2017; SRDB 

Ref ID: 169919

ORAUT (Oak Ridge Associated Universities Team), 2017-k, Interview Worker #11; documented 

communication with former Metals and Controls Corporation worker; October 26, 2017; SRDB 

Ref ID: 169922

ORAUT (Oak Ridge Associated Universities Team), 2017-l, Interview Worker #12; documented 

communication with former Metals and Controls Corporation worker; October 26, 2017; SRDB 

Ref ID: 169917

ORAUT-OTIB-0070, Dose Reconstruction During Residual Radioactivity Periods at Atomic 

Weapons Employer Facilities; ORAU Team Dose Reconstruction Project for NIOSH; effective 

March 5, 2012; SRDB Ref ID: 108851
White Paper Metals and Controls Corp. Subsurface Exposure Model April 23, 2018

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This is a working document prepared by NIOSH’s Division of Compensation Analysis and Support (DCAS) or its contractor for use in discussions 

with the ABRWH or its Working Groups or Subcommittees. Draft, preliminary, interim, and White Paper documents are not final NIOSH or 

ABRWH (or their technical support and review contractors) positions unless specifically marked as such. This document represents preliminary 

positions taken on technical issues prepared by NIOSH or its contractor. NOTICE: This report has been reviewed to identify and redact any 

information that is protected by the Privacy Act 5 USC §552a and has been cleared for distribution.

Sowell, 1985, Radiological Survey of the Texas Instruments Site Attleboro, Massachusetts, Final 

Report; L. L. Sowell, Oak Ridge Associated Universities (ORAU); January 1985; SRDB Ref ID: 

94371

Taulbee, 2018, Resuspension Factors During Excavation Activities, E-mail correspondence 

regarding Mound, with attachment; Timothy Taulbee; January 16, 2018; SRDB Ref ID: 170425

Texas Instruments, 1994, Supplement to the 1992 Remediation Plan, Rev. 0.0; Texas Instruments 

Incorporated; December 1994; SRDB Ref ID: 114177

Weston, 1996-a, Texas Instruments Incorporated Attleboro Facility Building Interiors 

Remediation Drainage System Characterization; prepared by Roy F. Weston, Inc.; January 1996; 

SRDB Ref ID: 165965

Weston, 1996-b, Texas Instruments Incorporated, Remediation of Exterior Areas Adjacent to 

Buildings 11 and 12, Final Report; prepared by Weston, Inc.; May 1996; SRDB Ref ID: 24625

Weston, 1996-c, Texas Instruments Incorporated Remediation of Building Interiors—Buildings 

4, 5, and 10, Report Version 1.0; prepared by Weston, Inc.; October 1996; SRDB Ref ID: 

114246